Penalty u/s 271D Overturned: Journal Entries Not in Breach of Section 269SS, No Malafide Intent in Transactions.

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....Penalty u/s 271D - entries through journal entries - Violation of provisions of section 269SS - round tripping of funds to evade taxes - proof of reasonable cause u/s 273B - these transactions were not made by the assessee with a malafide intent to evade tax and that there is no evidence brought on record to even remotely suggest that the assessee company by passing the aforesaid journal entries had sought to introduce its unaccounted income into the system. - it could be safely concluded that these entries neither reflect any receipt of loan nor repayment of loan. - AT....